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So, I finally have my answer. The FDA Compliance Office says I can label my cosmetic, natural soaps in one of two ways: either “AT FORMULATION” or “AT USE.”

“At Formulation” requires the listing of lye, either sodium hydroxide or potassium hydroxide.

“At Use” requires the use of the terms for the salts of the fatty acids that the oils become, for example, sodium cocoate, sodium palmitate.

Either customers have to be educated on the fact that lye reacts completely and is not present in the finished natural soaps, or that “chemical sounding names” are really just natural oils converted into soap.

I’m going with “At formulation,” which means you’ll see “Sodium Hydroxide” on my label. Please be assured that there is no lye in the finished natural soap bars! 🙂